ML20046A236

LER 93-008-01:on 930429,relief Request Improperly Prepared for Insvc Testing Program Results in Noncompliance W/Main Steam Isolation Valve Testing Requirement.Caused by Personnel Error.Testing Frequency Revised

ML20046A236
Person / Time
Site:	River Bend
Issue date:	07/22/1993
From:	Lorfing D GULF STATES UTILITIES CO.
To:
Shared Package
ML20046A237	List: ML20046A236 ML20046A426
References
LER-93-008, LER-93-8, NUDOCS 9307270131
Download: ML20046A236 (5)

Text

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TuPMONE NUM& R (mcLue f%a Gm D.N. LORFING, SUPERVISOR-NUCLEAR LICENSING (504) 381-4157 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13) j CAusE svsn v couPoNrNT MANur AC' user UA$E q CAVEC SYSTEV COVPONENT MANUFACTURER

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ABSTRACT (Limit to 1400 e. paces, i e . approximately 15 single-spaced typewntien lines) (16)

On April 29,1993, with the plant in Operational Condition 4 (Cold Shutdown), an investigation )

was initiated due to an apparent conflict between GSU's Safety Evaluation Report (SER)

concerning the in-service testing (IST) prognun for pumps and valves and the River Bend IST  ;

Program Plan. Pan of the SER. relief request (RR) #40, is worded such that it requires MSIV  ;

testing every cold shutdown. This is in conflict with the IST Prognmi Plan. However, since ,

it is pan of the SER, it is required pursuant to Technical Specification 4.0.5. During a coia ,

shutdown in December 1992, the MSIV testing requirement was not met. Therefore, GSU has  :

concluded that this event is reportable pursuant to 10CFR50.73(a)(2)(i)(b) as a condition prohibited by the Technical Specifications. i The root cause has been detennined to be personnel error when testing frequency changes were  :

processed on relief request #40 including the word "every." GSU has revised the MSIV fast full stroke testing frequency during cold shutdowns to be consistent ASME Section XI Subsection .

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FACILITY NAME C) DOCRET NUMBER (a LER NUMBER (S) PAGE (3) bEQJENisAL HE v4CN NUMBER NUMBER RIVER BEND STATION 05000 458 93 - 008 -

01 2 4 un v m e-ev.wn ~*. mar m e m e *w on REPORTED CONDITION On April 29, 1993, with the plant in Operational Condition 4 (Cold Shutdown), an investigation was initiated due to an apparent conniet between GSU's Safety Evaluation Report (SER) concerning the in-service testing (IST) program for pumps and valves and the River Bend IST Program Plan. Part of the SER, relief request (RR) #40, is worded such that it requires MSIV (*ISV*) testing every cold shutdown.

This is in condict with the IST Program Plan. However, since it is part of the SER, it is required pursuant to Technical Specification 4.0.5. During a cold shutdown in December 1992, the MSIV (*ISV*)

testing requirement was not met. Therefore, GSU has concluded that this event is reportable pursuant to 10CFR50.73(a)(2)(i)(b) as a condition prohibited by the Technical Specifications.

INVESTIGATION On April 23, 1993, at the request of NRC inspectors, GSU provided information concerning the RBS Safety Evaluation Report (SER) on the IST program for pumps and valves. The NRC expressed particular interest in RR #40, which is the cold shutJownjustification for testing the main steam isolation valves (MSIVs). The NRC inspectors raised the following questions:

1. Why was this cold shutdown justification worded differently than the rest of the cold shutdown justifications

2. Was RR #40, cold shutdown justification, reviewed and approved by the NRC?

Due to the concerns raised by the NRC inspectors a condition report (CR) was initiated on Ey 29,1993 to investigate these issues.

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GSU began an extensive search into the history of how this relief request was developed. Our investigation mto the history of RR #40 revealed that it was originally written for relief from quarterly full stroke testing by requesting that alternate testing be performed during refuel outages. This philosophy was later changed due to industry experience with MSIV testing. In 1987, General Electric l issued GE service information letter (SIL) 21 to address MSIV failures due to a loss of air. In 1988, an l addendum was issued to this document. In addition, the NRC had issued Inspection and Enforcement

( (I&E) Notice #85-84 concerning MSIV failures. A meeting was held at River Hend on December 15 and 16,1987 between the NRC, their consultants (EG&G Idaho Inc.), and GSU. The meeting was to discuss the questions raised by the review of the IST pump and valve program. The question on the MSIVs was to provide more specific technical justification for not performing full stroke exercising, fail safe testing, and stroke timing these valves on a quarterly basis. As a result of this meeting, it was agreed that a NRC FDRM 366A l$ th

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7ACILITY NAME 0) DOCKET NUMBER (2) LER NUMBER (6) PAGE (3)

SEGUE NT.AL FEV%c4 NUMBER NUMBER 05000458 OF RIVER BEND STATION - -

93 008 01 3 4 un wrenua. r. m ..n.uw,u e.w e m m on conservative approach would be to revise RR #40 which required full stroke testing every refueling outage. The revision would require the full stroke testing, under certain conditions, during cold shutdowns. The original relief request wa> worded as follows:

" A full stroke exercise test for each valve during every refuel outage."

When it was revised the words " refuel outage" were removed and " cold shutdown" added, and the word "every" was inadvertently left in place. Subsequently, RR #40 was reviewed and approved by the NRC.

The revision should have incorporated wording identical to the other cold shutdown justifications. The IST Program Plan has specific guidance as what the cold shutdown frequency is, and how cold shutdown testing is to be implemented. The program states that the valves shall be tested during cold shutdowns i but not less than every 92 days. Testing shall commence within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after achieving cold shutdown, but shall not prevent plant start-up. Completion of cold shutdown testing is not a prerequisite for commercial generation of power. Tests not completed prior to startup will be rescheduled for the next cold shutdown starting with the last test performed. Cold shutdown testing is not required if testing was performed in the last 92 days.

ROOT CAUSE The root cause has been determined to be personnel error when testing frequency changes were processed on relief request #40 leaving in the word "every." This implied that we would perform this testing every cold shutdown contrary to the direction given in our IST Program Plan. Because of this error, the relief request required performance every cold shutdown and caused a failure to comply in December 1992.

A review of previous LERs revealed no similar events.

CORRECTIVE ACTION Further evaluation of the applicable MSIV testing requirement provides insight as to the intent of RR #40 (more correctly Cold Shutdown Justification Request No. 40). ASME Section XI Subsection lWV-3411, and IWV-3416 " Test Frequency" states " Category A and B valves shall be exercised at least once every 3 months except as provided by IWV-3412(a), IWV-3415, and lWV-3416." IWV-3412(a) states "Vaives that cannot be exercised during plant operation shall be specifically identified by the Owner and shall be full stroke exercised during cold shutdowns." Request #40 was generated as a result of this requirement.

l The MSIV testing frequency for fast full stroke testing during cold shutdown is as follows:

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i FACILITV NAME v) DOCF ET NUMBER (2) LER NUMBER (61 PAGE (3)

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YEAR NJMBER NUMBER r RIVER BEND STATION 05000 4 5 8 OF .;

93 - 008 -

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Tw w me, ,e.c. ,, ,. a u.. .aanm,., .mo,m xs o n For intervals of 3 months or longer - exercise during each shutdown.

For intervals of less than 3 months - full stroke exercise is not required unless 3 months >

have passed since the last shutdown exercise.

Therefore, GSU will fast full stroke exercise MSIV's in accordance with ASME Section XI Subsection  ;

IWV-3411. I Surveillance test procedure (STP)-109-6302 has been revised to incorporate the new testing as described l above. All other cold shutdown justifications were reviewed. The intent of these justifications was j verified to require testing during cold shutdowns.  ;

SAFETY ASSESSMENT An Engineering review and analysis have shown that the condition indicated would not have placed the .

plant in a configuration beyond the safety analysis due to the missed performance of MSIV cold shutdown  !

testing. The acceptable monthly performance of STP-051-0201 and previous performance of STP-109-6302 during refueling outage 4 indicate the valves had acceptable performance until February 27,1993. ,

Recent review of the results of STP-051-0201 performed on that date and MSIV testing during an outage (April - May 1993) revealed that MSIV IB21*AOVF022B had stuck in the open position. However, based on acceptable monthly performances of STP-051-0201 until February 27, 1992, there is no i evidence of prior valve failure.

1 Note: Energy industry identification codes are indicated in the text as (*XX*).

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